ML20138N630
| ML20138N630 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/1985 |
| From: | Merschoff E, Trottier E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20138N407 | List: |
| References | |
| REF-QA-99900334 NUDOCS 8511050262 | |
| Download: ML20138N630 (33) | |
Text
0RGANIZATION: TRANSAMERICA DELAVAL, TNC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION INSPECTION N0.: 99900334/85-01 DATE(S): June 3-7, 1985 ON-SITE HOURS:
55 CORRESPONDENCE ADDRESS: Transamerica Delaval, Incorporated Engine and Compressor Division ATTN: Mr. C. S. Mathews, Vice President and General Manager 550 85th Avenue Oakland, California 94261 ORGANIZATIONAL CONTACT: Mr. B. Guntrum, Manager, Quality Assurance TELEPHONE NUMBER:
(415) 577-7422 PRINCIPAL PRODUCT:
Diesel Engines NUCLEAR INDUSTRY ACTIVITY: With the exception of an occasional replacement part or service, no current domestic nuclear industry activity, s
2 ASSIGNED INSPECTOR: M IM f62 Tn E. H. Trottier, Reactive Inspection Section (RIS)
Date DTHER INSPECTOR (S):
J. C. Higgins, Nuclear Engineer Brookhaven National Laboratary APPROVED BY:
- M49 #
ff E. W. Merschoff, Chief, HIS Dat'e INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR 50 Appendix B and 10 CFR Part 21.
B.
SCOPE: This inspection was performed to review corrective action taken by TDI on previous inspection findings. The specific area of concern that gave rise to this inspection relates to the manner in which TDI reports defects and noncompliances as required by 10 CFR Part 21.
PLANT SITE APPLICABILITY: Bellefonte 1/2, 50-438, 439; Catawba 1/2, 50-413, 414; Comanche Peak 1/2, 50-445, 446; Grand Gulf 1/2, 50-416, 417; Perry 1/2, 50-440,441; Rancho Seco, 50-312; River Bend, 50-458; San Onofre 1, 50-206; Shearon Harris, 50-400; Shoreham, 50-322; Vogtle 1/2, 50-424,425.
$$M0 % hh 0
P 99900334
~ ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 2 of 24 A.
INSPECTION ISSUES The issues that resulted in this inspection were:.(1) verifying satisfactory corrective and preventive actions for the 29 nonconformances from three inspections of Transamerica Delaval and two violations resulting(2) verifying that Transamerica Delaval, Inc.
Inc. conducted in 1983, and has established and implemented an effective 10 CFR Part 21 program.
B.
INSPECTION FINDINGS 1.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 10.4.1 of the Quality Assurance Manual and Section 2.4.1 of In-process Inspection Manual I.P. 300, a production route sheet was neither stamped nor initialled by a quality inspector to indicate acceptance of a production operation.
2.
Transamerica Delaval, Inc. has established a 10 CFR Part 21 program that is, with fev: exceptions, effectively implemented. Areas in need of improvement are: the Part 21 administrative procedures, and records of review and evaluation activities conducted in support of the Pn t 21 program.
3.
Corrective actions and measures to prevent recurrence for the 31 violations and nonconformances identified in previous inspections were, with the following exceptions, verified satisfactory:
Inspection 83-03: Nonconformance A remains unresolved, and Nonconformance E remains an open item.
C.
BACKGROUND Inspection topics for review within TDI's everall Part 21 program included:
required posting of Part 21 and related documents; the TDI procedure for establishing and administering Part 21 issues; procurement and subvendor control; and records related to Part 21 items. A discussion of the results of the review of TDI's Part 21 program is found in Section F,
Other Findings or Comments.
The general area of interest for this inspection was a revi2w of the corrective and preventive measures implemented as a result of previous inspection findings. Transamerica Delaval, Inc., has been visited by NRC inspectors six times since 1979, with three inspections occurring within four months in 1983 (83-01 in July, 83-02 in September and 83-03 in October). The series of inspections conducted in 1983 resulted in 2
. ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 3 of 24 violations and 29 nonconformances. This inspection addressed each of the 31 items of violation and nonconformance arising from the 1983 Vendor Program Branch inspections of Transamerica Delaval, Inc. The results are contained in Section F, Status of Previous Inspection Findings.
D.
UNRESOLVED ITEMS:
Unresolved items are matters about which more information is required.
The unresolved item arising f:om this inspection was initially identified as Nonconformance A, Inspection 83-03. As discussed below, corrective and preventive actions were insufficiently comprehensive to allow fully satisfactory resolution.
1.
Nonconformance A (Unresolved) Inspection 83-03:
TDI procurement specification for electrical control cables required only commercial grade cable, and did not require conformance to IEEE standards that require class IE cable be used on emergency diesel generators.
As a result of the use of commercial grade cable vice Class 1E cable on their diesel generators, a TDI Service Information Memo (#361, Rev.1, dated 10/13/83) and a 10 CFR 21 Report (dated 9/27/83) were issued to notify the NRC and all affected customers.
By way of corrective action, TDI has changed its parts list and purchased material specification to specify Class 1E cable.
An internal'QA audit was performed in April, 1934 to address the generic aspects of design control errors. With the exception of this application of Class 1E cable, no other design control discrepancies were identified as a result of that audit. The following paragraph substantiates insufficient corrective action taken to correct this nonconformance in its entirety.
The multi-conductor, commercial grade cable running fhom the engine terminal box to the Woodward governor actuator was previously rated for 75 C.
Because the cable runs so close to the engine, it was determined that the cable would exceed this rating if diesel room ambient temperature rose above 98.5 F(37 C). The new Class 1E cable is rated at 90 C.
A straight line extrapolation would predict that this rating would be exceeded if rocm ambient tempera-ture rises above 125.5 F (52 C). At least one nuclear power plant diesel room requires equipment be rated to withstand 130*F (ambient) due to ventilation system capacity. Thus, the new Class 1E cable temperature rating will be exceeded under that circumstance. Further review, analysis, testing or modification of this cable by TDI is appropriate.
~
ORGAN'IZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 4 of 24 E.
10 CFR PART 21 REVIEW The TDI Program for reporting defects and noncompliances in accordance with 10 CFR Part 21 was reviewed including:
the Part 21 procedure, posting of required documents and records related to Part 21 activities.
Various persons were interviewed regarding their role and responsibility with respect to the identification of defects for reporting under Part 21.
Overall, TDI appears to be conscientiously reviewing failures and defects for reportability under Part 21. Areas warranting improvement are discussed below; a.
Posting Both Part 21 and Section 206 of the Energy Reorganization Act were prominently posted throughout the facility.
However, the TDI Part 21 procedure was not posted. TDI corrected this by posting their procedure during the week of the inspection.
b.
Procedure The TDI procedure describing the Part 21 process is titled " Division 10 CFR 21 Policy," revision dated 5/31/85.
The inspector reviewed both the current and previous revision (dated 1/26/81) of the Part 21 procedure.
Defects or failures in TDI equipment are identified through a number of means including: verbal and written reports from field service representatives, warranty service orders, returned material reports, and QC inspection reports.
Items identified from these or other sources that are potentially reportable under Part 21 are evaluated by TDI, primarily via the Delivered Product Quality (DPQ) Committee.
The TDI Part 21 procedure is quite general and does not discuss specific responsibility for review of the various source reports for possible escalation into the Part 21 review system.
Likewise, there are no details in specific implementing procedures for these source reports that discuss responsibility for consideration of Part 21 in their review.
Several recent TDI purchase orders for nuclear parts were reviewed.
It was noted that while TDI imposed Part 21 on its subvendors, TDI was unable to produce a purchasing procedure or policy that mandated this practice.
5
O'RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION DAKLAND. CALITORNIA REPORT INSPECTION N0.:
99900334/85-01 RESULTS:
PAGE 5 of 24 Records maintained by TDI to assure compliance with Part 21 were marginal, particularly for items that were potentially reportable, but were evaluated by TDI and determined to be not reportable. The TDI Part 21 procedure provided no detail or guidance on the evaluation records to be kept in this situation.
c.
Review of Part 21 Files Selected items from TDI Part 21 files were reviewed, including failures that were ultimately determined reportable, as well as those that were determined to be not significant enough for reportability.
Additionally, significant failures and defects were selected from other TDI data systems and from non-TDI data banks. These were pursued and the inspector verified that they had been appropriately entered into the TDI Part 21 system for review and evaluation.
TDI items determined reportable are numbered sequentially, beginning with 101. Since beginning their Part 21 reporting program in 1978, TDI has reported 430 items. Tne files of the four items reported to date in 1985 were reviewed as follows:
Item 127: Air Filter, Control Panel Failure Item 128:
Starting Air Check Valve Failure Item 129: Crankshaft Oil Plug Sizing Item 130: Generator Control Panel Overheating These files were reviewed for proper Part 21 evaluation, correct documentatien, notification of affected plants, timeliness of reporting, and proper items included in the reports. No discrep-ancies were identified.
Records for items not reported under Part 21 were also reviewed.
In general, records oTTailures that were originally considered reportable, then by later evaluation determined to be not reportable, were marginal. The Part 21 procedure did not address the evaluation format. Thus, the record of an evaluation was often a set of hand-written notes not always dated'and signed. Despite the lack of good records, TDI did appear to be performing appropriate reviews of these items. Particularly noteworthy were the weekly inputs from each field service representative and the Warranty Service Orders that 4
were reviewed for potentially reportable items.
ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND. CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 6 of 24 One item was identified that may deserve further attention. This concerned a Georgia Power Co. (Plant Vogtle) control system defi-ciency that prevented the EDGs from automatically restarting within 90 seconds of a shutdown. On 1/29/85, TDI determined this to be not reportable, without good reason and despite a customer letter identifying it as a serious discrepancy and requesting a modification to correct it. During the course of this inspection, TDI agreed to reevaluate this item.
In a telephone discussion of this item subsequent to the inspection, TDI informed the inspector that they had reviewed the matter and found plant Vogtle to be the only nuclear plant that had this 90 second " lockout." The TDI Engineering Department (Controls Group) has since redesigned this icgic circuit and issued new drawings that remove this " lockout" featu m.
F.
QUALITY ASSURANCE PROGRAM REVIEW Both 10 CFR 50, Appendix B, Criterion V and ANSI N45.2, Section 6, which TDI is committed to follow, call for activities affecting quality to be prescribed by appropriate instructions, procedures, and drawings.
It was noted that the recently revised TDI Quality Assurance Program Manual, Section 5, " Instructions, Procedures, and Drawings," was weakly worded in that it only described manufacturing and engineering type docunents.
Further review of TDI programs and program controls revealed a general lack of procedural coverage in certain areas (e.g., Quality Assurance, Repair, and Parts Activities). Specifically, there did not appear to be controlled and approved procedures for the following activities:
Completion of QC Inspection Reports Processing of Warranty Service Orders for failed items on EDGs in the field Processing of material and parts returned from the field for repair on Returned Material Request (RMR) forms The QA Corrective Action Request (CAR) Program Review of the audit of TDI performed in 1984 by the Management Assistance Corporation (MAC) revealed a similar finding, as follows: " Instructions, Procedures, and Drawings in QAM Section 5.0 should cover the broad scope of documents intended by this section of ANSI N45.2 and not just drawings and manufacturing process related documents."
ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKIAND. CALI:0RNIA REPORT INSPECTION N0.: 99900334/85-01 RESULTS:
PAGE 7 of 24 G.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
Inspection 83-01 (July 11-15, 1983) a.
Violation 1 (Closed): Transamerica Delaval, Inc. (TDI) had failed to issue a 10 CFR Part 21 report concerning a jacket water pump failure Shoreham Nuclear Power Station that occurred on Octobe. 11, 1982.
Following the failure, TDI conducted (and documented) a review of the circumstances surrounding the incident. Based on this review, TDI concluded (erroneously) that the failure was not reportable under the requirements of 10 CFR Part 21 because the pump assembly was unique to Shoreham.
(The inspector reviewed the documentation attendant to this Part 21 review).
TDI corrected this violation by issuing the required Part 21 report on July 20, 1983.
As preventive action, TDI committed to reexamine its Part 21 reporting philosophy and initiate administrative changes to ensure future problems similar to this will be reported.
b.
Violation 2 (Closed): TDI had failed to issue a 10 CFR Part 21 report concerning fuel injection line leaks at Shoreham Nuclear Power Station.
Following the failure, TDI conducted a review of the circum-stances and determined (erroneously) that since only Shoreham had experienced fuel injection line leaks, the problem was not in the tubing material supplied and thus was not reportable under 10 CFR Part 21.
However, subsequent to Vendor Program Branch Inspection 83-01, TDI issu'ed a Part 21 notificatfor, and identified two other nuclear sites that had received fuel injection line tubing from the same batch as Shoreham. TDI also recommended an inspection program to deter-mine if additional fuel injection line failures were imminent.
This recommendation resulted in Shoreham replacing 100% of the fuel injection lines on their engines. The remaining nuclear sites have experienced no failures of fuel injection line tubing to date.
'0RGAN'IZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 8 of 24 Preventive action was taken in conjunction with Nonconformance A, Inspection 83-01, below: additional inspection and material tests performed on material received; training conducted and documented on QA Manual requirements for receipt inspections; additional emphasis in this area on the next QA internal audit.
c.
Nonconformance A (Closed): Material (fuel injection line tubing) accepted without required mill test reports having been received or a nonconformance being issued.
TOI's corrective action commitment for this finding consisted of inspecting the subject fuel injection line tubing, which was received under vendor P. O. #45333. The inspector reviewed the nondestructive examination records of the tests performed on this tubing. The tests consisted of a 13 part metallurgical laboratory report and a magnetic particle test report. As a preventive measure, a new production routing sheet was developed that requires all tubing to undergo hardness, Magnaflux and metallurgical tests (by TDI Procedure NDE 600.30) upon receipt.
The inspector reviewed the following tubing purchase orders and verified that the tests were documented as being performed:
TUBING P.O. Number P.O. DATE 17558 5/2/84 55571 10/21/83 17873 5/22/84 18700 8/9/84 18947 8/30/84 19657 10/29/84 18479 7/16/84 Additional preventive action committed to by TDI r.nd reviewed by the inspector included a letter from the QA Manager to the Quality Control Supervisor requiring documented training of receiving inspectors (dated November 4. 1983); the record of such training conducted (December 12,1983); and the Audit Report of January 23, 1984, in which this area was a subject of the audit.
d.
Nonconformance B (Closed): Layout drawings for a redesign of the jacket water pump not properly drawn, nor signed and dated.
o 1
m.,
6RGANIiATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION JAKLAND CALIFORNIA 1
REPORT INSPECTION N0.:
99900334/85-01 RESULTS:
PAGE 9 of 24 The inspector reviewed TDI's corrective action commitment and found that Enterprise Standard (Form E 114) " Drawing Room Practice,"Section II.A, Layouts, was revised 11/8/83 and now reads, " Marked prints may be used in lieu of a layout for minor redesign if the intent of the design can be clearly conveyed."
Training records were also reviewed to verify preventive action.
The inspector found a training commitment memo from the Design and Drafting Group Supervisor dated Decemoer 4, 1983 and a similar memo from the Supervisor of Design Engineers dated November 17, 1983. Training was conducted on this finding and the revision to " Drawing Room Practice," on January 3, 1984.
e.
NonconformanceC(Closed):
Calculations for the redesign of.
jacket water pump not properly signed, dated or placed in the proper notebook.
TDI's corrective action was reviewed. The subject calculations were checked, signed, dated and properly recorded on an engine calculation sheet by the Manager of Engineering on November 9, 1983. TDI's action to prevent recurrence was to conduct training on the Drafting Room Practice Procedure, including the require-ments governing the Design Calculations Book. This training was conducted by the Manager of Design on November 17, 1983. The inspector reviewed the subject training documentation, which included the names of attendees (4).
f.
Nonconformance D (Closed):
"D Sheets", which are issued by the Engineering Department and pertain to the quality of the product, were not reviewed by the Department Manager.
release notices for To verify corrective action, the engineering (D-4956 and D-4986) the D Sheets that gave rise to this finding were reviewed. Each has been properly executed.
For preventive action, Engineering Operations Procedure #9, "O Shtets (Engineering Information System )" was prepared and approved on January 13, 1984, and revised on October 12, 1984. Additional preventive action taken irtcluded a training session on D Sheets and the new procedure, which was held on January 16, 1984.
To verify effectiveness of preventive action implementation, the inspector reviewed all D Sheets from January 1 through September 26, 1984. All were properly executed, reviewed (checked) and approved. A summary of this review is presented below:
O'RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND. CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 10 of 24 D SHEET No.
DESCRIPTION DATE 4947 Revise capacity of fuel 01/19/84 oil booster pump 4998 Cast Aluminum bearings 02/06-9/26/84 4999 High pressure fuel 03/15/84 injection line (shielded notheated) 5000 Mill chart for fuel pump 03/19/84 cam 5001 Fuel oil day tank 03/28/84 procedures 5002 Magnetic particle procedure 04/2/84 and standards 5003 Liquid particle procedure 04/2/84 and standards 5004 Process for cladding 04/27/84 babbitt alloy 5005 Magnetic particle procedure 4/12/84 and standards (Replaced D-5002) 9 Nonconformance E (Closed):
Route sheets for the assembly of a jacket water pump not retained by Quality Control.
No direct corrective action for this finding is possible, since the subject route sheets were never found. However, as the best available record of proper factory assembly, TDI obtained a copy of the Field Inspection Rsport that included acceptance criteria completed at Shoreham Nuclear Power Station on October 12, 1983.
The Field Inspection Report is a Shoreham startup document (S/U Form 7.6, revision dated October, 1982) and was reviewed by the inspector.
Preventive action consisted of a training program for all TDI personnel whose jobs require use of route sheets. Training was conducted on Demmber 13 (10 persons) and December 14, 1983 (3 p
ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION DAKIAND. CALI:0RNIA REP 0hT INSPECTION N0.: 99900334/85-01 RESULTS:
PAGE 11 of 24 persons).
In addition, TDI committed to make this subject an item for the next internal audit performed. The inspector reviewed the results of the internal audit conducted June 8 and 11, 1984.- A subject of this audit was Manufacturing In Process Control and Inspection (IP-300). All route sheets audited were properly stamped by a quality inspector.
h.
Nonconformance F (Closed): Two route sheets associated with the modification of jacket water pumps were not properly stamped and dated.
The route sheet dated October 11, 1982 (jacket water pump shaft) was reviewed and found to be incorrectly stamped.
Inspector 20 affixed his stamp in the space assigned to verify performance of operation 80, vice the space to signify inspection, space 90.
To correct this finding, inspector 20 re-stamped the route sheet in Space 90 and added an explanatory notation on November 8, 1983.
The route sheet dated November 14, 1977 (seal retainer rings) was corrected by entering the quar.tity accepted ("5").
Both route sheets were then stamped for final acceptance by Inspector 20 on November 8, 1983.
By way of preventive action, Inspector 20 attended the training session conducted on December 13, 1983, as referenced in Noacon-formance E, above.
1.
Nonconformance G (Withdrawn / Closed):
Failure to conduct dynamic analysis or seismic testing of redesigned jacket water pumps.
The original design of the jacket water pump was seismically qualified by " shake" testing in accordance with the purchase specification and TDI engineering standards. The redesign of the jacket water pump perfonned in 1982 was analyzed for requalification in the " Water Pump Shaft and Impeller Torsion Analysis" performed on October 13, 1982.
(This document was reviewed by the inspector). The analysis became a part of the "0ualification Statement for 03-425-04 Jacket Water Cooling Pump" dated October 18, 1982, which was also reviewed by the inspector.
The analysis and attendant statement of seismic qualification reveal that the design change was minor and, in fact, improved the seismic capability of the jacket water pump. Thus, TDI did not deviate from its engineering procedures, because paragraph 15.4.6 of E0P-1 states, "It may be noted that any items or
_ =. -.
ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND. CALIFORNIA REPORT INSPECTION N0.: 99900334/85-01 RESULTS:
PAGE 12 of 24 assemblies, once qualified for one contract, need not be requalified for subsequent jobs provided the response spectra are of comparable levels." The above referenced qualification showed the response spectra to be of comparable levels.
Based on the information presented above, which was not reviewed at the time of the original inspection, this Nonconformance is hereby withdrawn.
J.
Nonconformance H (Closed): A purchase material specification was not approved in accordance with TDI procedures.
TDI corrected this finding by properly approving the purchase material specification on November 11, 1983.
To prevent recurrence, the Product Engineering Manager was advised of the requirements of the governing TDI procedure.
Further, this item was made a ' subject of the internal audit conducted on April 5, 1984.
k.
Nonconformance I (Closed):
Failure to meet the date committed to for transmittal of 10 CFR Part 21 information to customers.
TDI committed to notify its customers regarding a potential problem with auxiliary drive couplings by July 15, 1982.
However, the subject notification letters were dated August 18, 1982.
Thus, this Nonconformance was corrected by the mailing, albeit 34 days late, of the required Part 21 notification.
To prevent recurrence, TDI conducted and documented training on the requirements of 10 CFR Part 21 and made this a subject of the internal audit conducted in March, 1984.
Further, TDI has revised its method of providing Part 21 letters to customers.
This is now accomplished by sending each customer a copy of the 10 CFR Part 21 notification letter sent to the Nuclear Regulatory Commission. The inspector' verified adequacy of this preventive action by reviewing all 10 CFR Part 21 reports (four) made by TDI in 1985. TDI has also established a " tickler" file to
, ensure that notification dates established in 10 CFR Part 21 reports are not exceeded.
I
ORGANI2ATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 13 of 24 2.
Inspection 83-02 (September 6-15,1983) a.
Nonconformance A (Withdrawn / Closed): TDI did not require its supplier of diesel generator exhaust silencers to have a Quality Assurance Program in effect for the components supplied to a nuclear power plant.
TDI's purchase order specifying four, Part #75CSI-12, 42 inch Model M-41 Exhaust Silencers was issued on 10/13/76 as P.O.
- 62643. The purchase order stated that the exhaust silencers were to be provided "In stri.:t accordance with Attached Specification 75051-120 Revision B dated 8-17-76, and Appendices 1,2,6,7 and 8."
Appendix 6 to Specifict. tion 75051-120, Revision B is a 28 page docume'.t titled " Quality Assurance Requirements for J 75051 (Perr3 Nuclear Power Plants, Units 1 and 2)," and is dated 6-jr-76. The purpose of Appendix 6 to Specification 75051-120, Revision B, is found on Page 3 and states, in part,
" Establish QA ano QC program requirements for procurement of items and manufacturing services...for Perry 1 and 2."
Based on the information presented above, which was not reviewed at *e time of the original inspection, this Nonconformance is hereby withdrawn, b.
Nonconformance B (Closed):
Inspection stamps and dates on route sheets did not provide proper evidence of inspection performance or acceptance.
Corrective and preventive actions for the two examples cited are detailed below:
1.
Corrective action for two missing cam gear bolts was accomplished when the engine was delivered to Shoreham Nuclear Power Station.
(No reports of this problem have been received from other sites). The route sheet for the cam timing and bolting operations previously was revised to improve the clarity of the requirements for these operations. TDI also revised the QA Manual section that addresses subassembly and assembly inspections on March 15, 1984; held two, one hour training sessions on the require-ments of inspection procedures; made this item a subject of the internal audit dated June 8 and 11, 1984. The inspector reviewed and verified the applicable ravision date of the QA Manual and route sheet, the training session attendance sheet, and the subject audit report.
,--..__p
'0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND C0!1 PRESSOR DIVISION 0AKLAND, CALIFORNIA
-8 REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
FAGE 14 of 24 ii. Corrective action for this item is not possible, as the piston rework was accepted by the customer at TDI, and the pistons shipped and installed at Southern California Edison's San Onofre Nuc' ear Generating Station.. The inspector reviewed the rework and shipping documents (Sales Order N-27693) and found that 3 pistons were shipped on March 5,1982 (Certificate of Compliance 82-176 dated March 4, 1982 and signed by TDI's A. E. Nance), 10 pistons were released by SCE's W. R. Mayberry and thipped on March 27,1982 (Certificate of Compliance 82-242 dated March 26, 1982 and signed by TOI's L. Block), and 10 pistons were released by W. R. Mayberry and shipped on March 31, 1982 (Certificate of Com 28, 1982 and signedbyL. Block)pliance82-248datepMarchThus, documents ga of the 23 pistons show all were inspected, accepted and documented as required.
As a result of this finding, TDI committed to revise their QA Manual in the section that addresses rework of customer property, conduct a training session on route sheets, and review route sheets for the six months following the training session.
The inspector reviewed Section 2.2.3.1. of the QAM and found that it was revised on March 15, 1984 to read as follows, " Rework customer property or items returned from field for repair or rework will be handled same as newly manu-l factured parts." Trcining records for the class held on December 13 and 14, 1983 were reviewed, and the review of 47 completed route sheets in the six months following the training session was verified.
c.
Nonconformance C (Closed): Rework' operations and documentation for Shoreham and Grand Gulf diesel generator pistons were not properly controlled.
The correct number of pistons at issue in this finding is 59; 26 pistons from Shoreham'and 33 from Grand Gulf.
It appears that in Inspection Report 83-02, Grand Gulf pistons were counted twice (59 plus 33 equals 92, and 33 plus 33 equals 66).
That would account for the totals given in the original Notice of Nonconformance (92 pistons reworked from Shoreham and Grand Gulf; 66 pistons reworked with no documentation).
In any case, a search of records at TDI has failed to locate the 59 route sheets. Thus, corrective rction for this finding is not possible.
0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION N0.: 99900334/85-01 RESULTS:
PAGE 15 of 24 Preventive action included revision of the QA Manual to better describe control of rework items, and a training program on the intent and importance of route sheet control. The inspector verified the revision of the QA Manual dealing with rework items (Section 2.3.3.1) is dated March 15, 1984 (Sea Nonconformance 8, above). Section 16.2.1 of the QA Manual was reviewed and found to describe the review of route sheets prior to release to stores (for shipping or inventory). This revision to Section 16 of the QAM is dated June 7, 1984. The training program committed to by TDI was held on March 22, 1984.
Eight attendees were present, including the supervisor of the Inspection Department. The training lasted one and one-half hours.
d.
Nonconformance D (Closed): Jacket water pump analyses not reviewed and certified by a Registered Professional Engineer (RPE).
Corrective action for this finding was accomplished by revising the TDI engineering procedures that address the requirements for approval by an RPE. These procedures were reissued as Engineering Quality Procedures 5, 6 and 7.
However, upon review by the inspector, these revised procedures still do not adequately define cases for which certification by an RPE is required. To remedy this remaining area of confusion, TDI has committed to provide a list of circumstances that will require certification of analyses / calculations by an'RPE.
It was also noted during this inspection that both the previous and current revision to the subject procedures require review and approval of calculations / analyses by the cognizant manager, and that the analyses in question had not been so approved. When brought to their attention by the inspector, TDI immediately had the items reviewed and approved by the Manager of Applied Mechanics.
Actions taken to prevent recurrence included mak'.3 this item a subject of tha audit performed on May 29, 1985 and having TDI engineering managers review and approve (by signature) all analyses between January, 1984 and this date. A sample of these analyses was reviewed during the inspection.
No findings of nonconformance were identified.
e.
Nonconformance E (Closed):
Reports of nondestructive examinations performed on engine cylinder heads not initiated.
'0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPLCTION N0.: 99900334/85-01 RESULTS:
PAGE 16 of 24 Corrective action for this finding is not possible since all combustion cylinder components have been shipped to the site and installed.
However, other non-destructive examination records for the subject components were reviewed. Entries verified on the monthly " Casting and Machining Problems with RV-4 Steel Cylinder Heads" report show that magnetic particle examination was performed and indications repaired.
A summary of this report follows:
Head Serial No.
Repair Summary G-83 5 hot tears comb. side, 3 shroud side H-56 15 hot tears, 1 sand H-66 OK H-67 3 hot tears, 3 sand H-89 OK Material Test Reports for the following cylinder heads were also reviewed, with the following results:
Serial No.
NDE Procedure Date G-60 600-30 Addendum A (MT) 4-6-82 600-50 Addendum (UT) 4-6-82 H-89 600-30 Addendum A (MT) 6-10-82 600-50 Addendum (UT) 6-10-82 H-60 600-30 Addendum A (MT) 5-10-82 600-50 Addendum (UT) 5-10-82 In addition, route sheets for two cylinder heads were reviewed to verify performance of dye penetrant (PT) NDE:
Serial No.
Route Sheet Operation Inspector Date H-60 170 QC-30 3-23-83 H-89 170 QC-30 3-29-83
'0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION
_0AKLAND, CALIFORNIA REPORT INSPECTION N0.: 99900334/85-01 RESULTS:
PAGE 17 of 24 Previous TDI practice was to use the route sheet sign-off as evidence that all repairs and NDE were performed. While the test report was a compilation of the entire manufacturing, repair, and acceptance process, the NDE information was available elsewhere.
The following actions were taken to prevent recurrence of this finding: Training on the requirements of Inspection Procedure 600 was conducted for the Foundry QC Supervisor on February 3, 1984; the Inspection QC Supervisor on January 30, 1984; and mechanical inspectors and NDE tu.hnicians on October 14, 1983.
This finding was also made a subject of the internal audit of the foundry conducted on March 13, 1984.
In addition, forms documenting liquid penetrant and magnetic particle NDE have been revised to improve clarity.
f.
Nonconformance F (Closed): Some TDI employees performing NDE on cylinder heads were not certified NDE examiners.
Corrective action for this finding was accomplished by qualifying and certifying NDE examiners in accordance with applicable standards. This training course was held on October 14, 1983 for eight TDI employees.
It was conducted by a certified NDE Level III examiner.
Preventive action taken consisted of a letter to supervisors stating the TDI policy of not allowing non-certified personnel to perform NDE. This letter also listed the eight persons recently certified (corrective action above) to perform NDE.
Additional preventive action was accomplished by making this item a subject of the next internal audit. The inspector verified the results of this audit that showed 61 liquid penetrant examinations were performed and stampec' by qualified NDE examiners between February 8 and April 25, 1584.
In addition, th% inspector noted that 37 route sheets were verified by TDI as being properly documented for NDE requirements during the audit conducted on May 3 and 4, 1984.
g.
Nonconformance G (Closed):
Improper construction of NDE practical examinations and the TDI Level III radiographer did not maintain continuous certification.
Corrective action for this finding was accomplished by requali-fying all TDI NDE personnel using a properly constructed 10
'0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AN1 COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 18 of 24 point practical evaluation portion of the examination. The inspector reviewed the NDE qualification records for all 3 NDE testers and found that each had a 10 point practical evaluation portion of the examination.
Requalification for all three NDE testers was completed on October 24, 1983.
(Exami-nations in radiographic, magnetic particle, dye penetrant and visual NDE methods). The inspector also reviewed the TDI approved suppliers list for radiographic NDE vendors and found that Transworld Testing was last audited by TDI in February, 1983. Their approval lasts until February,1986. TDI last purchased radiography services from Transworld in May 1985 (Purchase Order #34808) as evidenced by Certified Test Report CN 6406 dated May 10, 1985.
Preventive action was accomplished by requiring a 10 point check list as part of the TDI NDE qualification procedure; maintaining a Level III examiner in all NDE disciplines or subcontracting such services; reviewing implementation of the corrective actions during the next internal audit. The inspector noted that the internal audit conducted March 13, 1984 reviewed the corrective and preventive actions of this finding and determined them satisfactory.
h.
Nonconformance H (Closed):
Route shcats not properly stamped
~
or initia11ed by inspectors, and re-use of a surrendered inspection stamp before the mandatory 6-month waiting period had elapsed.
Corrective action for this finding is not possible since all inspection activities are complete and the subject components have been shipped to the site for installation.
Training on the requirements for proper completion and documen-tation of route sheets was completed in conjunction with preventive action for Nonconformance E of Inspection Report 83-01 and Nonconformance B, above (a training course given December 13 and 14, 1984 for 13 TDI inspectors).
Further preventive action was taken in a new revision of the In Process Inspection Manual dated May 1, 1985, that states, in part,
... inspector will stamp or initial and date the Production Routing Sheet, Form P-135B, in the space provided."
J Additional preventive action was taken by developing a new log in which the issue status of inspection stamps is recorded. The Stamp Assignment Log has six columns by which stamps can be 4
' ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900324/85-01 RESULTS:
PAGE 19 of 24 traced. Column headings are: Stamp No., Inspector Name; Issue Date, Cancel Date, Name (Re-Assign), and Reassign Date. This item was a subject of the internal audit conducted June 8 and 11, 1984; no findings were identified.
1.
Nonconformance I (Closed): A weld machine and heat treat furnace out of calibration.
To correct this finding, TDI recalibrated all weld machines and heat treat furnaces, then added them to their calibration recall system. The effectiveness of those corrective and preventive actions was verified satisfactory during the internal QA audit conducted in March, 1984. The inspector reviewed selected weld machines and heat treat furnace calibration records during this inspection. No discrepancies were identified. A plant tour was also performed to inspect machine calibration stickers. All machines and furnaces were either in calibration or posted "Out of Service-Do Not Use."
Calibration was performed by Pacific Calibration Services, who is on TDI's list of approved suppliers.
J.
Nonconformance J (Closed): Weld procedure being used did not match procedure specified on route sheet.
Corrective action for this finding was accomplished by revising the route sheet for hard facing valve seats.
The subject route sheet was revised to require weld procedure 100-W-17A (vice 100-W-17) on October 11, 1983.
(The correct weld procedure was being used when this finding w)as identified, the route sheet specified the previous revision.
Preventive action for this finding was accomplished by revising the specification for hard facing valve seats.
Specification 100-A-1, Addendum A, Rev, O dated March 22, 1984 now calls for procedure 100-W-17A to be followed when hard facing valve seats.
This item was the subject of the internal audit of June 8 and 11, 1984.
No discrepancies were noted.
k.
Nonconformance K (Closed): Completed route sheets not retained by Quality Control.
Corrective action for this finding is not possible since the assembly route sheets have never bean found. Manufacturing route sheets were, however, retained by QC and were examined by the inspector.
0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION 0AKLAND, CALIFORNIA REPORT INSPECTION N0.: 99900334/85-01 RESULTS:
PAGE 20 of 24 Preventive action for this finding was accomplished by revising the procedure that governs control and retention of route sheets for manufacturing and assembly. The results of this preventive action were aJited by TDI on June 8 and 11, 1984.
No discrep-ancies were found.
1.
NonconformanceL(Closed): Certificates of Compliance for combustion cylinder heads furnished to Shoreham Nuclear Power Station (SNPS) were not notarized.
Historically, The Architect Engir.eer (Stone & Webster) for Long Island Lighting Company (owner-operator of SNPS) has chosen not to require performance of specification SH1-89 (notarized Certificate of Compliance) by TDI. However, to correct this finding, TDI wrote a letter to the Long Island Lighting Company (LILCo) Purchasing Agent asking if they wished to now enforce this portion of the specification.
(Letter dated March 6, 1984). The inspector reviewed tPe reply, dated March 26, 1984, which stated,1 i part, "...notari-zation is not required for any Certificate of Ccmpliance submitted by Transamerica Delaval Incorporated to Long Island Lighting Company for parts supplied in accordance with SH1-89."
For preventive action, all TDI Quality Engineers were advised of this item of noncompliance and the need to review carefully all future contracts for such comitments.
3.
Inspection 83-03 (October 17-21,1983)'
a.
Nonconformance A (Unresolved): A discussion of this item is found in Section D, of this report, " Unresolved Items."
b.
Nonconformance B (Closed): Written instructions not provided and a weld report not completed for welding fuel oil line clamp brackets.
Ccrrective Action Request (CAR) 120 was issued on February 13, 1984 to address this finding. CAR 120 requires: Manufacturing receive instruction through the route cheet indicating the correct weld procedure to be used; the assembly department supervisor instruct the welder as to what weld procedure to use; the inspector verify that the correct weld procedure was used, the weld is acceptable, and the welder is qualified.
1
\\-
0'RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND. CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 21 of 24 To assure corrective action implementation and prwent recurrence of this finding, the Manager of Quality Assurance was assigned to audit this area during the following internal audit. This item was a subject of the audit conducted on June 8 and 11, 1984.
No discrepancies were noted.
c.
Nonconformance C1 (Closed): Material from which ASME Code Class 3 component supports and, fuel oil systems were fabricated was purchased from vendors not on TDI's Approved Suppliers List or audited by TDI.
Corrective Actio: C1: Of the six vendors who supplied inaterial for support; and fuel oil systems supplied to two nucl0ar stations, only one (Coulter Steel Forge Co., N-Cert. #h-1189 issued 8/04/75 and expired 8/4/78) was properly authorized to be on TDI's Approved Suppliers List (ASL). The remaining five vendors were placed on the list after completing a self-audi.t-mail-in survey short form (P-268). Corrective actico for thts s finding was to remove all suppliers from the ASL and use c@s/c ASME Code Certificate holders or companies audited by TDI. Since 1980, TDI has used only such suppliers for nuclear materials with the exception of Bethlehem Steel, Co., Burress Harbor, Indiana, which was audited by TDI. The inspector reviewed the report of this Audit, which was conducted on May'3, 1980.
The audit was performedin accordance with NCA 3800 using Form P-324, as follows, " Audit conducted in accordance with the rules of NCA 3820 because no QA certificate held by Bethlehem Steel Co.
for steel plate. Overall evaluation-Facility approvea as material manufacturer of steel plate per [NCA] 3820." Removal of improperly approved suppliers and the enforced policy of TDI to use only properly approved suppliers, or those holding valid ASME certificates, is the preventive action for this finding.
d.
NonconformanceC2(Closed):
Prior to 1982, ASME Code Class 3 fasteners were purchased from vendors neither 'on TDI's Approved Supplier's List nor audited by TDI.
Corrective Action C2:
Since March of 1982, TDI has purchased Code fasteners from Sargent Nut and Bolt, a distributor of Power, '
andEngineeredProductsCo.(PEPCo). The inspector examined '
PEPCo's Quality Certificate (QSC #399 dated March 3, 1980s'.o March 3, 1983). QSC #399 was renewed by PEPCo on February'25, 1983, and has a current expiration date of March 3, 1986.
dRGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND. CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 22 of 24 e.
Nonconformance D (Closed):
Receipt inspection of Code fasteners did not assure compliance with Purchase Order. Specifically, the material composition of the faster.crs did not meet requirements, mechanical test data was incomplete and heat treatment informa-tion was missing.
Corrective action for this finding was accomplished by performing laboratory and physical tests to establish material composition and strength of the fasteners. The following table presents the material test results as reviewed by the inspector:
Bolt Test Yield Tensile Elongation Area Heat No.
Date (PSI)
(PSI)
(%)
Red. (%)
N-37268 2/29/84 134,100 144,300 19 60 N-35238 2/29/84 126,700 135,600 18 65 N-54957*
2/29/84
- Bolt from Heat N-54957 was too small for the pull bar.
The tests were performed and certified by physical test labora-tory #4-113, Testing and Controls Co. The strength tests indicate that the requirements of ASME Section II, Table 1 of SA 325 were satisfied. Material composition tests were performed by spectroscope on February 27, 1984, with the results found to be in compliance with the purchase order.
Preventive action has been accomplished by revising the QA Manual requirements of receipt inspection and its relationship to Quality Engineering as follows:
"All material or item certifi-cations / documents are reviewed by the Receiving Inspector for compliance with the Purchase Order. After this review, the Receiving Inspector contacts Quality Engineering for their review and acceptance of the documents for compliance to the codes and standards." This change to the QA Manual is found in Control of Purchased Material, Items and Services, Section 4.0 of the Third Edition, Revision 0 dated April 10, 1984. This change was reviewed and approved by a representative of the Hartford Steam Boiler Company (TDI Authorized Nuclear Inspector) on April 11, 1984.
f.
Nonconformance E (0 pen): This finding involves fasteners (nuts, bolts and screws) that were purchased as stock material and subsequently certified as being in compliance with ASME Code
'0RGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NO.: 99900334/85-01 RESULTS:
PAGE 23 of 24 Section III, yet the applicable material requirements of the Code were not met.
To date, TDI has not addressed the issue central to this finding. To wit: TDI has not accepted that a material check-analysis is required by ASME Code Section 3867.4e(2), and thus the material is not in compliance with Code requirements.
Further, TDI has not proposed adequate corrective action (e.g., notify purchasers of such fasteners that they may not comply with Code requirements).
Preventive action proposed by TDI is to purchase ASME Code material only from suppliers having a current ASME Quality Certificate.
In addition, material documentation is now reviewed by a Receiving Inspector for compliance with the purchase order, and a Quality Engineer for compliance with applicable codes and standards, g.
Nonconformance F (Closed): Discrepancies were noted between inventory records used in the TDI storage area and the material used in construction of some engine piping system supports.
This finding was corrected by deleting Form P-316, Material Control Record, from the TDI QA Progran.
Form P-316 was the document used to keep track of material in storage at TDI, while the Material Verification Sheet is the official record of material used in component manufacture. The inspector reviewed the current copy of the QA Manual and found Form P-316 deleted.
In addition, the Code Data Package for P.O. NY435079 (starting air system) was reviewed and found to contain the required Material Verification Sheet to be reviewed by the Authorized Nuclear Inspector.
h.
Nonconformance G (Closed): Prior to 1981, the TDI foundry did not perform stress relief heat treatment on model AN piston skirts as specified in engineering drawings. As a result of this lack of stress relieving, some model AN piston skirts cracked in service.
Corrective action for this finding was accomplished through the issuance of a 10 CFR Part 21 report dated October 28, 1982.
In the Part 21 report, the six utilities that received these piston skirts were identified (each was sent their own copy of the 10 CFR Part 21 report) and advised to either return them to TDI for proper stress relieving, or replace them with properly manufactured model AE piston skirts. The inspector sampled TDI records to verify that the affected utilities properly responded to this Part 21 notification.
i l
1 ORGANIZATION:
TRANSAMERICA DELAVAL, INC.
ENGINE AND COMPRESSOR DIVISION OAKLAND. CALIFORNIA l
I REPORT INSPECTION l
NO.: 99900334/85-01 RESULTS:
> AGE 24 of 24 1
Preventive action committed to by TDI in their letter of March 2, 1984 has been fully accomplished. Their commitment was in the form of Corrective Action Request (CAR) 121, which was initiated by TDI on February 13, 1984 and closed on September 24, 1984.
This CAR directed that foundry heat treat charts be revised to l
better control and document heat treat activities, and required a documented review of engineering drawing heat treatment requirements. Better control and documentation of foundry heat I
treatment is now afforded through a new Heat Treat Load Chart (Form P-396). The new chart indicates Series Number, Heat Number and Part Number.
In addition, TDI performed a failure analysis (FA Report #153, dated June 20,1983) on the circum-stances surrounding the heat improper treatment of Model AN piston skirts.
It was established that there was some confusion between the material and associated hardness requirement for I
the ductil fron used to make the piston skirts. While the material composition had a tensil strength of 80,000 psi, the heat treatment specification called for hardness equivalent to 100,000 psi material.
Since the material and its heat treatment for hardness were incompatible, TDI changed the material specifi-l cation to 100,000 psi tensil strength material and has replaced i
all AN piston skirts with the newly designated model AE piston skirt.
H.
EXIT INTERVIEW The single nonconformance identified during this inspection, as well as the resolution status of all previous violations and nonconformances, were discussed with TDI management at the exit interview.
l
PERSONS CONTACTED 4NSAbtfd/C4 h/AL Dates,7bNP 3-7. / 9 A S Company _
Docket / Report No.99 9CO734 86-OI Inspector 2 M. 6I2m 6 7/ &
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